cecl implementation: what you need to know · cecl implementation: what you need to know. p create...
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WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
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August 6, 2019
CECL Implementation: What You Need to Know
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Disclaimers
The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting, or tax advice or opinion provided by CliftonLarsonAllen LLP to the user. The user also is cautioned that this material may not be applicable to, or suitable for, the user’s specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The user should contact his or her CliftonLarsonAllen LLP or other tax professional prior to taking any action based upon this information. CliftonLarsonAllen LLP assumes no obligation to inform the user of any changes in tax laws or other factors that could affect the information contained herein.
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Housekeeping
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• Q&A session will be held at the end of the presentation.
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About CLA
• A professional services firm with three distinct business lines– Wealth Advisory
– Outsourcing
– Audit, Tax, and Consulting
• More than 6,100 employees
• Offices coast to coast
• Serving 1,500+ financial institutions
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC.
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Speaker Introduction
• David Heneke and Josh Juergensen are principals within CLA’s financial institutions practice, working with financial institutions across the country. They both focus 100 percent of their time on certified audits, internal audits, and other consulting services for financial institutions.
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WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
Recent Developments
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Proposed Extension
• July 17 FASB Meeting
– Proposed dividing implementation into two buckets◊ Publically Traded, excluding small reporting companies
◊ Everyone else (implementation would be 2023)
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ASU 2019-04
• Accrued Interest
– Accounting policy election, several options
• Recoveries
– Should be included when estimating the allowance for credit loss
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ASU 2019-04
• Selling Costs on Probable Foreclosures
– Specifically requires an entity consider the estimated costs to sell if it intends to sell
• Contractual Extensions and Renewals
– An entity should consider extension options that are included in the original or modified contract and are not unconditionally cancellable by the entity
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ASU 2019-05
• Provides an option to irrevocably elect the fair value option on an instrument-by-instrument basis for eligible instruments
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WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
Current Allowance Levels and CECL Expectations
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Current Allowance Levels (As of March 31, 2019)
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Industry Wide Net Charge-Off Data (12/31/18)
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Large Institution Charge-Off Curve
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Large Institution Trend Analysis
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Community Institution Charge-Off Curve
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Community Institution Trend Analysis
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CECL Assumptions
• Allowance will go up
• Reserve for life instead of incurred
• Reasonable and supportable forecast period
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CECL Versus Incurred Comparison
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WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
Qualitative Factors/Industry Data Analysis
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Qualitative Factors/Forecasting
• Historical loss rates will continue to be adjusted for qualitative factors and forecasting
• Select a reasonable and supportable forecast period and adjust historical information
• Federal Reserve data can assist with this analysis
https://cdr.ffiec.gov/public/
https://research.stlouisfed.org/fred-addin/
https://fred.stlouisfed.org/graph/?g=4VT
https://www.ncua.gov/analysis/credit-union-corporate-call-report-data/quarterly-data
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Qualitative Factors/Forecasting
• Mathematically support qualitative factor adjustments.
• Regression analysis.
• Are there any correlations between your data and an economic data point?
• Level of sophistication will depend on if your data can be correlated.
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Qualitative Factors/Forecasting
• Use of industry data
• Correlate economic items to industry data
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Correlations/Forecasting
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Unemployment Rate vs Chargeoff Rate
Annualized Chargeoff Rate Unemployment Rate
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Correlations/Forecasting
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WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
Screen Share
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WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
Data
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Model Selection
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• Complexity versus accuracy of utilizing multiple methodologies
• Importance of risk rating accuracy, timely update and tracking
• Changes to policies, procedures, and process controls
• Consistency of assumptions across models
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Data Elements
• Note Number
• Purpose Code
• Original Amount
• Current Principal Balance
• Origination Date
• Renewal/Extension Date
• Maturity Date
• Risk Rating
• Charge-off and Recovery Data (with date and note)
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Data Elements
• Interest Rate
• Payment Amount
• Payment Frequency
• Prepayment Expectations
• Narrative to Support Inputs
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Data Collection
• Additional data collection may be necessary depending on how granular you want to get
• Other elements may include loan to value, debt service coverage, credit scores, etc.
• You do not want to get too granular, as you may end up with very small pools that will not be statistically relevant
• Verify you can obtain the elements mentioned above at various points in time
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Closing Thoughts
• Statistically supporting qualitative factors will be a challenge for community institutions
• Tools are available to assist with forecasts
• Qualitative and forecasting adjustments are going to continue to be a significant component of the allowance calculation
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WEALTH ADVISORY | OUTSOURCING | AUDIT, TAX, AND CONSULTING
Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor
Questions?
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CLAconnect.com
Thank you!
David Heneke, [email protected]
Josh Juergensen, [email protected]